On March 20, TEI submitted comments in response to a request for comments in Notice 2023-2, which provided guidance on the stock repurchase excise tax. The comments requested carve-outs from the tax for redemptions of nonparticipating, nonconvertible preferred stock and addressed the funding rule and related per se rule that… Read more »
Editor’s note: This article was written in mid-December 2022. It is expected that by the time of publication, the US Department of Treasury and the Internal Revenue Service may release guidance to address some issues this article discusses. The corporate alternative minimum tax (CAMT) was enacted as part of the…
On January 25, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) regarding the OECD’s public consultation on the design elements of Pillar One, Amount B. TEI’s comments included the need to broaden the scope of Amount B to achieve its goal of transfer pricing simplification, ensure… Read more »
Thirty-eight states rang in the new year with significant changes to their tax codes. Most of these state-level changes were spurred by a wave of rate reductions and other tax cuts over the past two years, greater tax competition during a time of greater mobility, and, of course, inflation, according… Read more »
On November 17, TEI submitted comments to the Internal Revenue Service on proposed changes to Schedule UTP. The comments identified various critical policy issues that must be evaluated in a thoughtful and deliberative manner and urged the IRS to put an indefinite hold on the proposed changes and engage in… Read more »
Business transactions such as mergers, acquisitions, and business reorganizations often require valuations of intangible assets. Applying different standards may result in different valuations for the same intangible asset. It is therefore important to identify the appropriate valuation standard before attempting any valuation of an intangible asset. Significant differences may arise…
2023 Tax Technology Seminar April 24–26 San Diego, CA Leadership Foundations Seminar June Virtual Federal Tax Course – Level 1 June 12–16 East Lansing, MI Federal Tax Course – Level 2 July 17–21 Atlanta, GA Annual Meeting of Members August 6–8 Newberg, OR US International Tax Course August 13–18… Read more »
Environmental, social, and governance (ESG) considerations command a continually growing share of attention in organizations of all types as various stakeholder groups sharpen their focus on sustainability, equity, and accountability. Today more and more investors, consumers, and employees make decisions based on an organization’s ESG strategy, policies, and actions. As…
On December 9, TEI submitted written comments to Congress regarding the changes to Section 174 under the Tax Cuts and Jobs Act of 2017. The comments urged Congress to act before the end of the 2022 calendar year to postpone, if not repeal, the mandatory capitalization of expenditures under Section… Read more »
On February 3, TEI submitted comments to the Organisation for Economic Co-operation and Development (OECD) regarding the GloBE Information Return under Pillar Two of the OECD’s project on the digitization of the economy. The Institute’s comments primarily focused on ways to reduce the volume of information required under the return,… Read more »
